Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 6675

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

para 1. Introduction
The treatment of housing numbers references the Oxford to Cambridge Arc but does not make clear how that has influenced the number of new homes proposed in the Draft Local Plan 2040. The Introduction should state clearly whether the 25500 new homes proposed by 2040 includes an allowance for a housing demand generated by the Oxford to Cambridge Arc project and if it does, state what it is, either as a number of new homes or as a percentage of the 25500 total.

Object

Representation ID: 6676

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

para 2. Vision and Objectives. Theme 1:Greener.

The convoluted wording dealing with the Borough by 2040 being “greener, more sustainable etc.” leaves it unclear what the commitment of the Borough is to actually achieving the Vision and Objectives. Phrases such as “integrates closely with the surrounding landscape”, “facilitating the development”, “Equipped to respond”, etc allow for a variety of interpretations including that the Borough is preparing the ground for the Objectives proving unachievable with 25500 new houses. Since references to Environmental Net Gain elsewhere in the Plan are all phrased positively, i.e., there is no doubt expressed or inferred that it can and will be achieved with this level of housing growth, we would wish to see “Theme 1: Greener” similarly phrased as follows;

“Deliver growth and an urban and rural green infrastructure network that protects, enhances and extends landscapes, woodland. biodiversity, heritage sites, green spaces and paths while also protecting and enhancing our natural resources, including air, water, soils and minerals. Deliver growth that, through location and the use of best available design and technology, minimises pollution and mitigates the potential impacts of climate change including flooding, drought and weather extremes. “

Object

Representation ID: 6677

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

para 3. Growth and spatial strategy options. 3.1 Level of housing growth required.
Cardington Parish Council fully supports the comments of the Campaign to Protect Rural England; Bedfordshire Branch and looks forward to the Borough’s response, either accepting that the Draft Plan’s housing growth level should be substantially reduced or providing a detailed and quantitative case countering the CPRE’s proposals.

Object

Representation ID: 6683

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

para 3. Growth and spatial strategy options. 3.10 – 3.17 Growth strategy options.

The (Draft) Sustainability Appraisal Report Evidence Base document clearly shows in Appendix 5 that the Spatial Strategy Options differ significantly in the feasibility, extent or even possibility of achieving the Vision and Objectives, Theme 1: Greener, and Environmental Net Gain. The Appendix does not attempt to rank the Options overall, however, and as this is not a task within the competence of Cardington Parish Council, we are unable express a preference.

We hope that such an analysis is carried out as a response to this consultation but from what we can see from the preliminary work of the (Draft) Sustainability Analysis, none of the options is able to deliver the Plan Objectives Theme 1: Greener or Environmental Net Gain.

Object

Representation ID: 6684

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Para 7. Development management policies. 7.30 – 7.40 Natural environment policies.

We do not think that the Environmental and Biodiversity Net Gain approach, as currently formulated, treats the protection and enhancement of water resources adequately. Any further development of housing and the employment and transport infrastructure accompanying it will add to demands for water supplies, management of waste water and affect the pattern of flow of surface water to rivers, water courses and groundwater reserves. The additional infrastructure needed to satisfy the demand for water supply and manage waste water will additionally have an impact on water resources, particularly so in our already water-stressed region.

Cardington Parish Council has raised the need for a proper assessment of water resource impacts in every Local Plan consultation since 2002. With the evidence of steadily increasing climate change impacts on this crucial natural resource this is probably the last chance we have of recognising the issue and managing our response.

We urge that Local Plan 2040 either;
i) includes a detailed and authoritative analysis of what the impact of 25500 additional homes would be on the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them would be or
ii) admits that such an analysis has not been carried out and that the impacts of local Plan 2040 on water resources are unknown.

Object

Representation ID: 6685

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Policy NE1 – Environmental net gain.

This policy is fundamentally flawed in that it proposes to deliver Environmental Net Gain on a site-by-site management basis on the unfounded assumption that the end result of 25500 houses in 2040 can be achieved with an Environmental Net Gain.

As the Policy admits, achieving Environmental Net Gain may mean enhancing or creating off-site habitats. Other important environmental issues, which should also be listed in the Policy such as maintaining or enhancing water permeability, managing surface run-off and treatment of waste water, are also likely to require off-site measures. Similarly, building and infrastructure development standards cannot be left to site-by-site decisions but must be specified as a result of analysing what standards are necessary for the total development target.

The Plan must offer evidence that 25500 houses can be achieved with Environmental Net Gain and the protection of crucial resources such as water, together with minimum standards, specified through Policy NE1, that every development must comply with in order to achieve this. If it does not do this, a site-by-site management process alone runs the risk of demonstrating, sometime before 2040, that Environmental Net Gain and protection of water resources can only be achieved within a housing target less than 25500.